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Adviser Profile

As of Date 10/01/2024
Adviser Type - Large advisory firm
- An investment adviser (or subadviser) to an investment company
Number of Employees 69 1.47%
of those in investment advisory functions 20
Registration SEC, Approved, 5/21/2008

Client Types

- Investment companies
- Pooled investment vehicles
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses
- Educational seminars/workshops

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Recent News

Reported AUM

Discretionary
Non-discretionary
9B 8B 6B 5B 4B 3B 1B
2015 2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Private Funds Structure

Fund Type Count GAV
Fund TypeVenture Capital Fund Count1 GAV$66,362,459

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Brochure Summary

Overview

Even�de Asset Management, LLC (“Even�de”) is a Delaware limited liability company that has been registered with the U.S. Securi�es and Exchange Commission (“SEC”) as an investment adviser since May 2008. Even�de provides values- based investment advisory products and services to a diverse client base, on a discre�onary and non-discre�onary basis. Even�de’s ethical values are inspired by the Chris�an faith and rooted in a biblical worldview. Even�de manages several values-based investment strategies, seeking to invest in companies iden�fied as having strong fundamentals and crea�ng value for stakeholders (customers, employees, supply chain, community, environment, and society). Principal Ownership There are two principal owners of Even�de (greater than 25% ownership): Dr. Finny Kuruvilla, Even�de’s Co-Chief Investment Officer, a Senior Por�olio Manager and Managing Director of Even�de’s private fund and Mr. Robin John, Even�de’s Chief Execu�ve Officer. Further informa�on on Even�de’s ownership structure is provided in Part 1 of Form ADV. Investment Strategies, Products and Services Even�de is a values-based investment adviser seeking to iden�fy companies having strong fundamentals and crea�ng value for stakeholders (customers, employees, supply chain, community, environment, and society) in the evalua�on of investment opportuni�es and the construc�on of investment por�olios. Even�de applies its values-based investment framework to a wide range of strategies, products and services offered on a discre�onary and non-discre�onary basis. Eventide uses its values-based screening processes to help establish each strategy’s eligible investment universe. Securities are generally ineligible for purchase within a strategy, unless Eventide’s research indicates that the values-based screens are met. Although there is no guarantee that Eventide will be able to successfully screen out all companies that are inconsistent with the following principles, Eventide seeks to invest in companies that reflect the following values:
Respecting the value and freedom of all people: this includes the right to life at all stages and freedom from addictive behaviors caused by gambling, pornography, tobacco and alcohol.
Demonstrating a concern for justice and peace: this includes fair and ethical relationships with customers, suppliers, and business partners and avoidance of products and services that promote weapons production and proliferation.
Promoting family and community: this includes protecting children from violent forms of entertainment and serving low-income communities.
Exhibiting responsible management practices: this includes fair dealing with employees, communities, competitors, suppliers, and customers as demonstrated by a company’s record regarding litigation, regulatory actions against the company, and its record of promoting products and services that improve the lives of people.
Practicing environmental stewardship: this includes practices considered more sustainable than those of industry peers, reduction in environmental impact when compared to previous periods, and/or the use of more efficient and cleaner energy sources. Securities might be sold when Eventide believes they no longer represent relatively attractive investment opportunities or when Eventide believes the underlying company is no longer consistent with Eventide's principles. Application of Eventide's values-based screening criteria could cause an Eventide strategy to underperform similar strategies that do not have such screening criteria. This could be due to ethically acceptable companies falling out of favor with investors or failing to perform as well as companies that do not meet Eventide's values-based screening guidelines. E V E N T I D E ___________________________________________________________________________________________________________________________ 5 As of the date of this Firm Brochure, Even�de’s values-based investment strategies include, but are not limited to, the following:
• Balanced Strategy
• Core Bond Strategy
• Dividend Growth strategy
• Dividend Value strategy
• Healthcare & Life Sciences strategy
• Large Cap strategy
• Limited-Term Bond strategy
• Strategic Growth strategy
• Technology strategy Even�de offers a variety of discre�onary and non-discre�onary products and services, to a wide variety of client account types as described below. Even�de’s advisory services are generally tailored to the investment products it manages and services it offers. Please see the descrip�on of Even�de’s products and services set forth below. Types of Client Accounts Eventide’s clients generally fall within one of the four account types and receive a service level as described below: 1. Unrestricted Accounts: This account type reflects discretionary institutional clients for which Eventide maintains full discretion over portfolio and brokerage decisions. This includes determining trade execution strategies for pooled investment vehicles and separately managed accounts (“SMAs”) unencumbered by any trading-related restriction, direction or other limitation required by clients. For instance, Eventide determines the time and price of transactions, broker-dealer selection, and whether to effect transactions using soft dollar commissions, commission sharing arrangements (“CSAs”), or through other means. 2. Managed Account Programs: This account type reflects clients that Eventide services through various managed account programs sponsored by third parties. Examples include wrap account programs and so-called “dual contract” arrangements in which end-clients access SMA strategies by contracting with their program sponsor and with money managers such as Eventide. Eventide generally provides investment strategies to these clients by delivering model-based portfolios directly to the program sponsor for implementation. Managed account programs generally serve a range of client types, including institutions and retail investors (e.g., entities and individuals). Program sponsors generally define requirements for trade implementation within their respective platforms. 3. Restricted Accounts: This account type reflects discretionary institutional clients of Eventide that either: i.) direct Eventide to effect trades with one or more specific brokers; ii.) restrict or otherwise limit Eventide’s discretion to effect trades such as with certain brokers; iii.) restrict or otherwise limit Eventide’s discretion to effect transactions using soft dollar commissions or CSAs), and/or iv.) otherwise impose service levels that impinge Eventide’s ability to seek best execution in the opinion of Eventide. 4. Non-Discretionary Accounts: This account type reflects institutional clients such as program sponsors electing to receive non-discretionary portfolios delivered by Eventide after NYSE market close, periodically as determined by clients (e.g., daily, weekly, quarterly, etc.). The program sponsors maintain full investment and trading discretion E V E N T I D E ___________________________________________________________________________________________________________________________ 6 over transactions in their client accounts, including determining whether to implement all, some, or none of the securities recommended by Eventide. Products and Services Mutual Funds. Even�de provides por�olio management for mutual funds (the “Mutual Funds”) registered under the Investment Company Act of 1940, as amended (the “1940 Act”). Even�de manages the Mutual Funds as described in each Mutual Fund’s prospectus and statement of addi�onal informa�on. Such documents also explain in greater detail how each Mutual Fund u�lizes Even�de’s applicable investment strategies and risks, fees, and other factors to consider before inves�ng (please see htps://mutualfunds.even�deinvestments.com/). As of the date of this Firm Brochure, Even�de manages the following Mutual Funds:
• Even�de Gilead Fund
• Even�de Healthcare & Life Sciences Fund
• Even�de Dividend Opportuni�es Fund
• Even�de Balanced Fund (formerly known as Even�de Mul�-Asset Income Fund)
• Even�de Exponen�al Technologies Fund
• Even�de Limited-Term Bond Fund
• Even�de Core Bond Fund
• Even�de Large Cap Focus Fund The Mutual Funds are generally managed by Even�de according to the strategies iden�fied above. Even�de’s strategies are delivered in fixed-income securi�es in coordina�on with a sub-adviser hired to manage all or a por�on of assets in certain Mutual Funds, as disclosed in the applicable prospectuses. As more fully described in each Mutual Fund’s prospectus and statement of addi�onal informa�on, there is no guarantee that any Mutual Fund will achieve its objec�ve. Investment markets are unpredictable and there will be certain market condi�ons in which Mutual Funds will not meet their objec�ves. Each Mutual Fund’s net asset value and returns will vary. Investors could lose all their money on their investments. Private Fund. At the �me of filing this Firm Brochure, Even�de provides discre�onary investment advisory services to a private fund, the Even�de Healthcare Innova�on Fund I, LP (the “Private Fund”). The Private Fund is offered pursuant to Regula�on D of the Securi�es Act of 1933 (the “Securi�es Act”) and excluded from the defini�on of an investment company under Sec�on 3(c)(1) of the 1940 Act. Even�de manages the Private Fund as described in its limited partnership agreement and private placement memorandum (“PPM”). The Private Fund’s investment strategy is dis�nct from Even�de’s Healthcare & Life Sciences strategy referenced above. The Private Fund’s investment strategy overlaps with a por�on of the investment strategy u�lized by certain Mutual Funds. Even�de maintains policies, procedures, and controls to help address conflicts associated with side-by-side inves�ng, as described more fully within this Firm Brochure, applicable Mutual Fund disclosure documents, and the Private Fund’s PPM. As stated in the PPM, there is no guarantee that the Private Fund will achieve its objec�ve. Investors should understand and be capable of bearing the significant risks of inves�ng in the Private Fund, have a limited need for liquidity, and can withstand losing their en�re investment. An investment in the Private Fund is suitable only for ins�tu�ons and individuals that sa�sfy the condi�ons set forth in the applicable subscrip�on documents. E V E N T I D E ___________________________________________________________________________________________________________________________ 7 Ins�tu�onal SMAs. At the �me of filing this Firm Brochure, Even�de provides discre�onary investment advisory services to eligible ins�tu�onal clients invested in separately managed accounts (“Ins�tu�onal SMA”). Ins�tu�onal SMAs are generally managed in accordance with the strategies described above, pursuant to specific investment strategies, guidelines and management fees nego�ated between Even�de and its eligible Ins�tu�onal SMA clients. Each of Even�de’s Ins�tu�onal SMA clients is unique, and their investment needs can vary. As such, Even�de’s investment strategy may be modified as necessary to meet specific client investment objec�ves. Even�de’s Ins�tu�onal SMA clients will execute an investment management agreement iden�fying the investment objec�ves and restric�ons and any reasonable client restric�ons. Prior to the opening of the client account, Even�de will review any requested investment restric�ons and work with the client to refine them as necessary to meet the client’s needs, as well as provide Even�de with adequate flexibility to manage the account. Even�de’s investment management agreement with Ins�tu�onal SMA clients will include a Statement of Investment Objec�ves and Restric�ons that describes the investment objec�ve and approach, the types of investments in which a strategy will invest, any applicable investment or brokerage restric�ons requested by the client, and applicable risks associated with inves�ng in the strategy. Ins�tu�onal SMA clients should understand and be capable of bearing the significant risks of inves�ng in such accounts, including the risk of losing their en�re investment. Clients should review the Statement of Investment Objec�ves and Restric�ons carefully prior to signing the investment management agreement. Even�de manages Ins�tu�onal SMA strategies side-by-side with commingled funds in which Even�de or its employees have an economic interest, and proprietary accounts. For more informa�on on how Even�de manages associated conflicts, please see item 6 – Performance Based Fees and Side-By-Side Management. Model-Delivered SMAs. Even�de provides its investment management services in the form of model por�olios comprised of individual securi�es (“Model-Delivered SMAs”). Even�de provides Model-Delivered SMAs either: 1.) through various managed account programs sponsored by third par�es where Even�de delivers model por�olios directly to a program sponsor for implementa�on; or 2.) through the delivery of a model por�olio (in the specified frequency), where a program sponsor maintains full investment and trading discre�on over transac�ons in its client accounts, including determining whether to implement all, some, or none of the securi�es recommended by Even�de. As more fully described in marke�ng material and other informa�on describing Model-Delivered SMAs, there is no guarantee that any Model-Delivered SMA will achieve its objec�ve. Investment markets are unpredictable and there will be certain market condi�ons in which Model-Delivered SMAs will not meet their objec�ves. Risks and returns will vary for each Model-Delivered SMA strategy. Investors could lose all their money on their investments. Even�de manages Model-Delivered SMAs side-by-side with other account types inves�ng in the same investment strategy, including discre�onary commingled funds in which Even�de or its employees have an economic interest, and proprietary accounts. For more informa�on on how Even�de manages associated conflicts, please see item 6 – Performance Based Fees and Side-By-Side Management. The way Even�de delivers its Model-Delivered SMAs differs depending on the type of client account. For Managed Account Program clients, Even�de delivers updated model por�olios directly to the third-party sponsor for implementa�on by the sponsor pursuant to the sponsor’s trading discre�on. For Non-Discre�onary Account clients, Even�de delivers updated model por�olios to a financial intermediary or third-party sponsor, who maintains full investment and trading discre�on over transac�ons in its respec�ve client accounts. Such financial intermediary or sponsor will determine whether to implement all, some, or none of the securi�es recommended by Even�de. As a result of these differences, a Non-Discre�onary Account client inves�ng in an Even�de Model-Delivered SMA will experience E V E N T I D E ___________________________________________________________________________________________________________________________ 8 different results, compared to the results experienced by Managed Account Program clients inves�ng in the same Model- Delivered
SMA strategy. Similarly, a Non-Discre�onary Account client inves�ng in an Even�de Model-Delivered SMA might experience different results, compared to other Non-Discre�onary Account clients inves�ng in the same Model- Delivered SMA strategy. For Managed Account Program clients, Even�de generally delivers an updated Model-Delivered SMA por�olio to the program sponsor contemporaneous with the �me it begins handling trade orders on behalf of its Unrestricted Accounts (and any Restricted Accounts for which the applicable restric�on is not relevant to the transac�on at hand.) As simultaneous delivery to all Managed Account Program clients is not possible, Even�de will deliver updates to these clients in an order assigned by a randomiza�on program, to help ensure no one client is systema�cally advantaged or disadvantaged. However, due to the randomiza�on program and the fact that the sponsor retains trading discre�on over Managed Account Program clients, it is possible that a Managed Account Program client account inves�ng in a Model- Delivered SMA strategy will experience different results from another Managed Account Program client account inves�ng in the same Model-Delivered SMA strategy. Further, because Even�de delivers updated Model-Delivered SMA por�olios to Managed Account Program clients contemporaneous with the �me it begins handling trade orders on behalf of its Unrestricted Accounts (and any Restricted Accounts for which the applicable restric�on is not relevant to the transac�on at hand), there is a risk that client accounts in all three categories may receive less favorable transac�on execu�on quality than they would otherwise receive. For Non-Discre�onary Account clients, Even�de delivers updated model por�olios to the third-party sponsor periodically as determined by clients (e.g., daily, weekly, quarterly, etc.). Even�de expects there will be a delay between the transac�ons Even�de ini�ates on behalf of its Unrestricted Ins�tu�onal, Managed Account Program, and/or Restricted Ins�tu�onal client accounts, and Even�de’s delivery of updated Model–Delivered SMA por�olios to Non-Discre�onary Accounts. These circumstances can lead to less favorable transac�on execu�on quality for Non-Discre�onary client accounts, and nega�vely impact the performance of Non-Discre�onary client accounts, as compared with other Even�de accounts pursuing the same investment strategy. As Even�de does not maintain discre�onary authority over these client accounts, and the financial intermediary can choose to accept or reject all or any por�on of the recommenda�ons in Even�de’s Model-Delivered SMAs, a Non-Discre�onary Account client will experience different results than other Non- Discre�onary Accounts invested in the same Model-Delivered SMA strategy. For more informa�on on the delivery of non- discre�onary Model-Delivered SMAs, please see Item 12 – Brokerage Practices. Tailoring of Services Even�de’s advisory services are generally tailored to the investment products it manages and services it offers. The way Even�de manages one of its investment strategies for one client account may vary from the way it manages the same strategy for another client or account. For instance, Even�de will tailor its management of Mutual Funds to generally include transac�ons in private companies or other illiquid securi�es, including par�cipa�on in IPO transac�ons or secondary offerings, transac�ng in deriva�ves, making short sales, or transac�ng in income-genera�ng securi�es typically reported on IRS Schedule K-1s. Also, consistent with Even�de’s values, the Mutual Funds may invest in securi�es that fund community development ins�tu�ons and serve needs such as those of low-to-moderate income families and communi�es. Conversely, Even�de will tailor its management of Ins�tu�onal SMA or Model-Delivered SMA products in the same strategy to prohibit such securi�es and transac�ons, except in circumstances where clients have expressly agreed otherwise. E V E N T I D E ___________________________________________________________________________________________________________________________ 9 Similarly, while Ins�tu�onal SMAs are managed similarly to other client accounts and account types inves�ng in the same strategy, Even�de modifies its investment strategies as necessary to meet specific client investment objec�ves. Further, Even�de u�lizes an investment strategy for its Private Fund that is dis�nct from the Healthcare & Life Sciences strategy referenced above, as appropriate for Private Fund clients with different liquidity considera�ons and as outlined in its PPM. Incidental Consulting Services Even�de offers investment consul�ng and guidance services to financial intermediaries, including investment analyses, por�olio illustra�ons and educa�onal content concerning values- and faith-based inves�ng. In addi�on, Even�de engages in public advocacy and educa�onal ini�a�ves related to values- and faith-based inves�ng. Even�de’s consul�ng and educa�onal services o�en reference faith-based viewpoints and/or investment services offered by third par�es. Even�de’s consul�ng and educa�onal services are incidental to its provision of investment advisory products and services. Even�de generally does not charge a fee for these incidental services, except as noted below. Even�de receives a financial benefit if investments are made in Even�de products as a result of these incidental consul�ng and educa�onal services. Even�de employees providing the incidental consul�ng and educa�onal services described in this sec�on do not receive a direct financial benefit if investments are made in Even�de’s products or services. Target Risk Allocation Models. Even�de offers on a non-discre�onary basis, hypothe�cal por�olios comprised of the Mutual Funds, in weighted alloca�ons across five risk-based strategy models. Even�de’s Target Risk Alloca�on Models seek to offer exposure to a diversified por�olio of equity and fixed income asset classes through the exclusive use of the Mutual Funds. Each Target Risk Alloca�on Model targets a specific vola�lity and risk profile similar to a selected benchmark comprised of both equity and fixed income securi�es. Even�de does not currently charge a separate fee for maintaining and distribu�ng the Target Risk Alloca�on Models. They are made available to 1.) financial intermediaries considering investments in Even�de’s Mutual Funds on behalf of their clients; and 2.) certain Even�de employees that are registered representa�ves (“RRs”) of Foreside Fund Services, LLC (“Foreside”), an unaffiliated FINRA registered broker-dealer, for discussion with such financial intermediaries. Target Risk Alloca�on Models are provided on a non-discre�onary basis, and Even�de is not responsible for effec�ng por�olio transac�ons or determining whether any Target Risk Alloca�on Model or any Mutual Fund is appropriate for a par�cular investor or account. Financial intermediaries generally maintain discre�onary authority over their client accounts and can choose to accept or reject all or any por�on of Even�de’s Target Risk Alloca�on Model. As of the date of this Firm Brochure, Eventide offers the following five (5) Target Risk Allocation Models:
Defensive Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 10% domestic equities and 90% fixed income assets. The Defensive Model seeks to provide current income with low levels of volatility.
Conservative Income Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 40% domestic equities and 60% fixed income assets. The Conservative Income Model seeks current income through exposure to a wide variety of income producing vehicles consistent with low to modest levels of return volatility.
Income & Growth Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 60% domestic equities and 40% fixed income assets. The Income & Growth Model seeks current income while maintaining the potential for long term capital appreciation and balances exposure to stocks and bonds to help moderate return volatility.
Growth Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 80% domestic equities and 20% fixed income assets. E V E N T I D E _________________________________________________________________________________________________________________________ 1 0 The Growth Model seeks long term growth through an allocation to stocks and bonds and seeks capital appreciation while accepting the potential for high levels of return volatility.
Aggressive Growth Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 95% domestic equities and 5% fixed income assets. The Aggressive Growth Model seeks long-term capital appreciation through an allocation to stocks across market capitalization and larger allocations to smaller capitalization growth stocks with very high levels of expected return volatility. Portfolio Illustrations. Eventide offers customized values-based model portfolio illustrations to individual financial advisors and/or intermediaries. These portfolio illustrations are designed to educate financial intermediaries about the potential impact that utilizing values-based principles can have on an investment portfolio. Customized portfolio illustrations are provided to individual financial intermediaries upon request, as part of Eventide’s investment consulting services. Eventide does not currently charge a separate fee for providing these services. Eventide Center for Faith & Investing (“ECFI”). ECFI provides educa�onal resources to serve both financial intermediaries and individual investors interested in biblically faithful inves�ng. ECFI shares faith-based perspec�ves and learning resources through dedicated website pages, a Journal and Podcast for Faith & Inves�ng, and educa�onal courses designed to teach the biblical story of inves�ng and methods for implemen�ng faith-based inves�ng principles. As a mission-focused firm providing values-based services rooted in a biblical worldview, Even�de’s educa�onal services o�en reference faith-based viewpoints and/or investment services offered by third par�es. As of the date of this Firm Brochure, ECFI’s online live courses are offered at $495 per person, and in-person courses are custom quoted, taking into considera�on travel and accommoda�on costs for ECFI staff and meals, venue and par�cipant accommoda�ons. In 2024, ECFI plans on launching an online on-demand course offered at $295 per person and a free online on-demand course for individual investors. In certain cases, ECFI might in its sole discre�on offer discounts to financial advisors or individuals, allowing them to par�cipate in its educa�onal courses at a lower rate than others. Even�de considers a variety of factors in determining whether a discount is appropriate. Offering of a discount to a financial adviser presents a poten�al opportunity for Even�de to provide indirect compensa�on to that financial advisor, in exchange for the financial advisor’s investment in and/or recommenda�on of Even�de’s products and strategies to the financial advisor’s clients. To help mi�gate the appearance of conflict, Even�de prohibits discounts to financial advisors from being based on the financial advisor’s assets under management in Even�de products, and maintains policies and procedures to help ensure only appropriate criteria are considered in offering discounts. For par�cipants who successfully complete ECFI’s educa�onal courses, Even�de will issue the “Chris�an Theology of Inves�ng” cer�ficate. This cer�ficate does not convey a par�cular level of skill, training or exper�se with respect to investment advisory services, and in providing this cer�ficate to individuals who meet Even�de’s criterion, Even�de is not implicitly or expressly endorsing the knowledge, skill or experience of a cer�ficate holder. The term “Chris�an Theology of Inves�ng” is the intellectual property of ECFI, and may not be used without the prior writen consent of Even�de. Personal Memoir. Robin John, a Founding Member of Even�de and the firm’s Chief Execu�ve Officer, is currently authoring a book targeted for publica�on in 2025. The book will be a memoir about the story of Mr. John’s life, his role as a founder of Even�de, and his core, personal convic�ons related to values-based and faith-based inves�ng. Certain expenses incurred in connec�on with wri�ng the book will be shared by Even�de. Mr. John intends to use any revenue he receives from the book for charitable purposes and/or to further distribute and promote the book’s messages regarding E V E N T I D E __________________________________________________________________________________________________________________________ 1 1 values-based and faith-based inves�ng. Even�de and Mr. John an�cipate that the book will have indirect benefits to Even�de by helping to explain considera�ons and poten�al benefits associated with more purposeful inves�ng. Registered Representatives. Certain employees of Even�de are registered representa�ves (“RRs”) of Foreside and are compensated through Foreside to facilitate the distribu�on of the Mutual Funds or the Private Fund (collec�vely, the “Funds” and each a “Fund”). Compensa�on for sales of the Mutual Funds is paid through Foreside, with certain payments origina�ng from NLD, the Mutual Funds’ 12b-1 Distribu�on Plan, and/or Even�de's legi�mate profits. Compensa�on associated with purchases of the Private Fund is paid through Foreside from Even�de’s legi�mate profits. In addi�on, RRs (and other Even�de employees) might receive certain gains and/or distribu�ons made from the Private Fund in connec�on with performance-based fees charged to Private Fund investors. RRs also stand to receive compensa�on from Even�de in connec�on with investments made in Ins�tu�onal SMAs and Model-Delivered SMAs. The RRs interact primarily with financial intermediaries such as investment advisers, but might, from �me to �me, meet together with financial intermediaries and their clients or meet directly with prospec�ve Even�de clients or ins�tu�onal investors. RRs can also respond to general inquiries from members of the public. Generally, interac�ons are for educa�onal and informa�onal purposes and the RRs do not purport to provide investment advice addressing the specific circumstances, goals, and investment needs of financial intermediaries’ clients or other investors. Assets Under Management. As of December 31, 2023, discre�onary assets under Even�de’s management totaled $6,984, 451,470, comprised of assets in its Unrestricted Accounts (i.e. the Funds and Ins�tu�onal SMAs) and Restricted Accounts. As of December 31, 2023, Even�de did not have any Managed Account Program clients. As of December 31, 2023, $149,555,358 has been invested in Model-Delivered SMAs for Non-Discre�onary Accounts. Even�de does not deem investments for Non-Discre�onary Accounts as assets under its management.